Every one of our 28,000 members possesses a set of values and opinions; sometimes they are unique to the individual, and other times they fall in line with other CPAs' opinions on a certain issue. A crucial part of the NYS SCPA' s mission is to protect the interests of its members and the general public. To ensure the Society's official positions best serve that mission, the NYSSCPA has a longstanding series of processes in place to guarantee that every position taken by the NYSSCPA has been deliberated by all segments of the membership. They have a voice in the process through participating as committee members, serving in leadership roles, or simply sharing their concerns through phone calls and letters.
The Comment Letter Process
The comment letter process positions the Society as a prominent and respected leader on accounting, tax, and financial issues. But most important of all, it also promotes the professional interests of our members in conjunction with the interests of the profession and the public. In our most recent fiscal year, we issued 41 comment letters to a wide range of groups that included FASB, the International Accounting Standards Board (IASB), the IRS, the AICPA, and the New York State Board for Public Accountancy.
The NYSSCPA has codified a system that provides a consistent and equitable means of developing official Society positions through comment letters developed by task forces and statewide technical committees. When a committee decides that it wants to respond to an exposure draft or comment on an issue, the committee chair generally works with the committee's assigned oversight committee. If deemed necessary, other committees may give their insights. At this point, the president, vice president in charge of comment letters, and executive director become involved as well, and if the issue affects basic Society policy, it becomes the province of the board or executive committee. The relevant committee, or a subcommittee thereof, then works on the drafting of a comment letter for the president's approval.
How does this work in practice? It's easy to look at the record, because all of our comment letters are posted at www.nysscpa.org/page/society-commentletters. For example, read our December 2011 comment letter in response to a PCAOB concept release on auditor independence and audit firm rotation. The NYSSCPA strongly opposed the idea of audit firm rotation because that's the consensus we received from our members. Even before it reached the board of directors, a broad scope of membership input was consulted in writing that letter - the Accounting and Auditing Oversight Committee, the Auditing Standards Committee, and the SEC Practice Committee - some 80 members representing different practices and companies. This level of input ensured that the opinions represented the will of the membership.
Committees respond to legislation, exposure drafts, and other proposals, whether they come from Albany, Norwalk, or Washington. If a proposal affects CPAs, we're prepared to take a stand. The NYSSCPA has some 50 technical committees that address everything from the taxation of individuals to the entertainment industry. And each one of these committees is composed of members like you who are working in their particular niches each day and who have a sense of what the profession requires.
The importance of these committees in drafting Society comment letters and positions is why we so strongly encourage members to volunteer for committees - participation is an essential way of getting your voice heard. Participating on a committee allows members to shape Society policy - not inadvertently, but directly.
The Role of the Legislative Task Force
Legislative and policy changes from Albany are special, of course. Although many accounting and financial groups take stands on national issues, for state initiatives our members look only to the NYSSCPA to represent them. …